Federal Court Strikes Down USCIS 39-Country Adjudication Hold

On June 5, 2026, a federal court issued one of the most significant immigration rulings of the year. In Dorcas International Institute of Rhode Island v. USCIS, Chief Judge John J. McConnell, Jr. of the U.S. District Court for the District of Rhode Island vacated four U.S. Citizenship and Immigration Services (USCIS) policies that had frozen immigration benefits for nationals of approximately 39 countries since late 2025.

The ruling is nationwide. It is effective immediately. It requires USCIS to resume processing green cards, work permits, naturalization applications, and asylum determinations without nationality-based discrimination.

This article walks through what the ruling decided, what policies it struck down, what it means for affected applicants, and what may happen next.

The Short Version

USCIS had implemented several policies beginning in December 2025 that placed indefinite holds on immigration benefit applications for nationals of 39 designated countries. These holds affected Adjustment of Status (Form I-485), Removal of Conditions (Form I-751), Naturalization (Form N-400), Employment Authorization (Form I-765), and other benefit applications.

On June 5, 2026, a federal court ruled that those policies were unlawful and vacated them nationwide. USCIS is now legally required to resume processing the affected cases. The government is expected to appeal, but as of the date of this article, the ruling is in effect.

Background: The Policies That Were Struck Down

To understand the ruling, it helps to understand the policies it addressed.

In December 2025, following Presidential Proclamation 10998, USCIS issued Policy Memorandum PM-602-0192. This memo directed USCIS officers to place an adjudicative hold on all pending asylum applications and on benefit requests submitted by nationals of designated high-risk countries.

On January 1, 2026, USCIS issued Policy Memorandum PM-602-0194, expanding the hold to cover nationals of all 39 countries on the expanded travel ban list.

The memo applied broadly to most immigration benefits, including:

• Adjustment of Status (I-485)

• Removal of Conditions on Residence (I-751)

• Naturalization (N-400)

• Employment Authorization (I-765)

• Various nonimmigrant petitions and other USCIS benefits

USCIS also implemented a separate "significant negative factor" policy, directing officers to treat nationality from these countries as a negative factor in discretionary adjudications.

The practical effect of these policies was severe. Applicants who had filed correctly, paid fees, completed biometrics, and even attended interviews found their cases frozen indefinitely. Many lost work authorization, jobs, and lawful status while waiting for decisions that were not coming.

The June 5 Ruling: What the Court Decided

In a 135-page decision, Chief Judge McConnell vacated four USCIS policies and entered nationwide declaratory relief. The court found that the policies were:

• Contrary to law

• Arbitrary and capricious

• Implemented without proper rulemaking

• Based on a national security rationale the court found pretextual

The four policies struck down were:

1. The Benefits Hold Policy. Froze processing of work permits, green cards, naturalization, and other immigration benefits for nationals of 39 countries.

2. The Global Asylum Hold Policy. Halted processing of all asylum claims regardless of country of origin.

3. The Comprehensive Re-Review Policy. Required USCIS to re-examine and reopen previously approved benefits for applicants from the 39 countries.

4. A related directive addressing implementation of the broader freeze.

The court granted summary judgment to the plaintiffs on their Administrative Procedure Act (APA) claims. The relief is nationwide, not limited to specific plaintiffs in the case.

The Court's Reasoning

The court's decision rested on the Administrative Procedure Act, the federal statute that governs how administrative agencies must operate. Under the APA, agency action is unlawful if it is arbitrary, capricious, contrary to law, or implemented without proper procedure.

The court found USCIS exceeded its authority. While the President has authority under Section 212(f) of the Immigration and Nationality Act to restrict entry into the United States, that authority does not extend to halting adjudication of benefits for people already lawfully inside the United States.

The court also found the national security rationale offered by USCIS to be pretextual. As one example, the court noted that within weeks of imposing the holds as an "operational necessity" for national security, USCIS issued exemptions for athletes participating in the 2026 World Cup and the 2028 Summer Olympics. The court reasoned that a national security concern that disappears for sports events is not a genuine national security concern.

What This Means for Affected Applicants

The ruling has immediate practical implications for several groups.

Nationals of the 39 Affected Countries with Pending Cases:

If your case was frozen by the USCIS hold, the legal basis for that hold has been removed. USCIS is now required to resume processing your application. This applies to:

• Adjustment of Status (I-485) cases

• Removal of Conditions (I-751) cases

• Naturalization (N-400) cases

• Work Authorization (I-765) cases

• Other USCIS benefit applications affected by the hold

USCIS implementation has been uneven. Some cases continue to show as in "secondary review" even after court orders apply. If your case remains stuck, consulting an immigration attorney to assess whether intervention is needed may be appropriate.

Affirmative Asylum Applicants of All Nationalities:

The global asylum hold has been struck down. USCIS is required to resume processing affirmative asylum applications regardless of country of origin.

Applicants Whose Approved Benefits Were Re-Reviewed:

The re-review policy targeting previously approved benefits from the 39 countries has been vacated. USCIS cannot continue to apply that policy.

Nationals of the 39 Countries Filing New Cases:

The ruling removes the broad adjudicative basis for delaying new applications. New filings should be processed under normal procedures, though additional scrutiny may still occur on a case-by-case basis.

What This Ruling Does Not Do

It is important to be clear about what the ruling does not change.

The ruling does not strike down the underlying travel restrictions. The travel ban affecting entry into the United States for nationals of 39 countries remains in effect. The ruling addresses how USCIS processes applications from people already lawfully inside the United States, not who can enter the country.

The ruling does not change eligibility requirements. The substantive requirements for Adjustment of Status, Removal of Conditions, Naturalization, and other benefits are unchanged. Applicants must still meet all statutory and regulatory criteria.

The ruling does not eliminate USCIS discretion. Officers still have legitimate discretionary authority in cases that involve discretionary determinations. What the ruling does is prevent USCIS from using nationality alone as a categorical basis for indefinite delay.

The ruling does not affect the State Department's visa processing. The Department of State announced a separate pause on immigrant visa processing for nationals of 75 countries through consular processing abroad. That action is separate from the USCIS holds and is not addressed by the Dorcas ruling.

The Distinction Between Two Country-Based Policies

A common source of confusion in early 2026 was the existence of two separate country-based actions affecting immigration. The Dorcas ruling resolves one of them but not the other.

The 39-Country USCIS Adjudication Hold (now vacated): Affected USCIS processing of benefits for nationals of 39 countries. This is what Dorcas struck down.

The 75-Country Immigrant Visa Processing Pause (still in effect): A separate Department of State action affecting consular processing abroad. This does not apply to:

• Adjustment of Status filings made inside the United States

• Removal of Conditions filings

• Naturalization filings

For applicants pursuing marriage-based Adjustment of Status from within the United States, the 75-country pause is generally not the operative policy.

The Earlier Ruling: Doe v. Trump

The Dorcas ruling was not the first court decision against the USCIS hold policies. On April 30, 2026, U.S. District Judge Julia Kobick in Massachusetts issued a preliminary injunction in Doe v. Trump, finding the same policies likely unlawful. That ruling initially covered 22 plaintiffs and was later extended to 266 plaintiffs across the consolidated cases.

The Dorcas ruling differs from Doe in two important ways. First, Dorcas is nationwide in scope, not limited to specific plaintiffs. Second, Dorcas issued summary judgment vacating the policies entirely, rather than a preliminary injunction blocking enforcement against specific individuals.

Together, these rulings represent a substantial judicial rejection of the USCIS country-based hold framework.

What May Happen Next

Several developments are possible in the coming weeks and months.

Government Appeal. The government is expected to appeal the Dorcas ruling to the U.S. Court of Appeals for the First Circuit. The administration may also seek an emergency stay of the ruling pending appeal. If a stay is granted, the holds could come back into effect temporarily.

Implementation Compliance. USCIS must now adjust its internal processes to comply with the ruling. Implementation across field offices and case types may be uneven for some time. Affected applicants may continue to experience delays even as the legal basis for those delays has been removed.

New USCIS Policy Guidance. USCIS may issue new policy guidance reflecting the court's ruling. Any such guidance will need to operate within the legal framework the court has set out.

Possible New Policies. The administration may attempt to reach similar policy objectives through different mechanisms. If new policies are introduced, they could face their own legal challenges.

The legal landscape is fluid. Applicants and practitioners should monitor developments over the coming weeks.

Practical Considerations for Affected Applicants

If you are a national of one of the 39 affected countries and your case has been pending without movement since late 2025, the following may be useful:

The legal basis for the hold has been removed. Your case is no longer subject to a categorical freeze. USCIS is required to resume processing.

Implementation may be slower than the legal change. Even with the court order in effect, USCIS may take time to formally remove holds from individual case files. Continued delays are possible.

Consulting an immigration attorney may be appropriate, particularly if your case has been pending for an unusually long time or if you have suffered loss of work authorization, status, or other tangible harm as a result of the hold.

The marriage-based Adjustment of Status, Removal of Conditions, and Naturalization pathways remain legally available. The substantive legal framework for these benefits has not changed.

Conclusion

The June 5, 2026 ruling in Dorcas International Institute of Rhode Island v. USCIS represents a major judicial rejection of the country-based adjudication holds USCIS implemented beginning in late 2025. The ruling is nationwide, immediate, and based on the Administrative Procedure Act.

For nationals of the 39 affected countries with pending immigration cases, the ruling means the legal basis for indefinite delay has been removed. For practitioners and applicants, the ruling restores the substantive framework that applied before the country-based holds were imposed.

The situation continues to develop. The government is expected to appeal, and new policy responses are possible. For now, the legal pathways remain available and processing should resume.

Sources and Further Reading

• Dorcas International Institute of Rhode Island v. USCIS, No. 1:26-cv-00132 (D.R.I. June 5, 2026)

• Doe v. Trump, No. 1:25-cv-13946-JEK (D. Mass. April 30 and May 7, 2026)

• USCIS Policy Memorandum PM-602-0192 (December 2, 2025)

• USCIS Policy Memorandum PM-602-0194 (effective January 1, 2026)

• Presidential Proclamation 10998 (December 16, 2025)

This article is for general educational purposes. It is not legal advice. For questions about your specific situation, consult a licensed immigration attorney.